~OMMI S S
ION OF THE EUROPEAN COMMUN
IIJC(90)601 fInalBrussels, 20 April 1990
TO PARLIANENT AND THE COUNCil
Gu I de II nes on company
(communication from the commission to the Counc II and to the European Par II ament)
1.The purpose of this communlcat Ion Is to set out the guidelines which
the Commission plans to follow In the field of company taxation and the measures which It thinks shoUld be taken at Community level to create a company tax env Ironment
ta Ilored to the estab
II shment and
furtherdeve lopment of the
Interna I market.
2.The first part of the communication Is given over to an examination of the tax problems that will need to be resolved between now and complet
Ionof the Internal market by the end of 1992. The general analysis Is
supplemented by an account of the measures that should be taken as a matter
of pr lor I tybetween now and 31 December 1992.
The second part 8x.amlnes the procedure to be followed In the face of closer Integrat Ion of Member States' economies.
I NTRODUCT ION
A tax strategy geared to the requirements of economic Integrat Ion
3.According to conventional economic analysis, any form of company
taxation Is liable to bring about economic distortions (lack of neutrality) because It may give rise to decisions on the location, nature and financing
ofInvestment would not have been taken In the absence of company taxation.
Such distortions ar Ise because company taut Ion Introduces a bias Into the
thatIn the Communi ty context the extent of this tax bias on an
Member States depending On
character 1stIC8 of the tax system.
theoreticalviewpoint, the possibility
considered of harmonizing national
company tax systems at
level so as to enSure complete tax neutrality.
are anumber of
Community should hold back on the harmonization of company tax
Member States should
remain free todetermine their
except where these would lead to maJor distortions.
analysis Isnecessary to
such distortions, and
decisions as to the location of
Quite apart from the differences In the tax burden on
otherfactors determining the decisions of
These Include, for example, the need to locate a proJect close to
costs, thequa II ty of pub II c
services and economic
Inv lew of
conclusion that community action
essential for completing the
Internal market. TheImportant question
of the advisability and possible forms of the harmonlzat Ion of company
taxation should be
reexamined closely and on
The tax prOblems to be
resolved andthe measures to be
I n taxprob I ems posed by cross-
f ront I er cooper
a t Ion
The SingleEuropean Act defines
Internal market as "
persons, services and capital Is
Commun I ty ,
erned. By Its
double taxation, and this
turn places an equivalent extra burden on companies.
9.Now, one of the alms of the Internal market Is to enable
economic benefits of
between national systems, community measures are heeded.
AI thoughbilateral double taut
Ion agreements have
helped to reduce the extent of
obstacles, they are far
market. This Is because they do
achievecomplete abolition of
double taxation and In particular
11.In the case of the setting-up of transnational companies, the
obstacles encountered stem from the system of taxation of
realized onmergers, divisions, contributions of assets or
enterprisesfrOlll different Member States.
Although taxation of
operations within aMember State
generally deferred until the
capital gains are
there Is nosuch possibility for transnational operations, where
theresu I tant
Such obstacles are
restricted only tocompanies with
capital but may
enterprises which do
Personality, whiChIs the case, for example, with many small and
med lum-s I zed
In the case of
thefunctioning of groups of
tax obstacles are
mostImportant obstacle lies
the withholding taxes applied by a large maJority of Member States
Member State to
I ts parentcompany I ~ another Member State.
Member States according to different rules and procedures.
known as "transfer prices
Nat lona I tax admlnlstrat Ions may decide to
adJust these pr
In their view,
they do notcorrespond to the prices that would be
f I xed
condl t Ions
unrestrictedcompetition. Where the upward adJustment of a
which Is deemed to be
low by the
taxadministration In a
Is not accompanied by a
the tax base In the other Member
State, double taxat
At themoment such double taut
admittedly beresolved by
conventions, In accordance with
Article 25 of
In all cases, It does notrequire the
agreement. Inpract Ice,
therefore, thI s
Instrument hasshown Itself Incapable of resolving all
14. A third
enterprise to set against Its profits the
permanent estab II shments or subs
I dl ar lesabroad. 1
Inequality oftreatment where transfrontler activities are
Member State In which the head office Is
located are an
theresu I ts
between apermanent establishment and
means, In .some Member states,
lossesIncurred by the
permanent estab II
shment are notdeduct I b
I ts made by
office. As a
enterprise pays an
tax that Is excessive In terms of Its total net results, since tax
Is applied to
the resultsachieved solely In the Member State
which the head office Is located.
arise InMember States which
case ofprofits, avoid
Member States which
establishment allowdeduct Ion
foreign losses. To
that thepermanent establishment earns
year, the sums
deducted are rEI-
Incorporated Into the head off Ice
resu I ts and
affectssubsidiaries although the legal position
Is not the same as In the case of permanent establishments. This
subsidiaries set up onnational territory are concerned, not
Member States allow
theirlosses to be set off against the
t~ allowed, ItIs subJect to
There arealso obstacles that Impede the
and Interestwithin groups of
within aMember State,
differing rates of withholding tax are levied In the case of most
ItIs true, be
set offagainst the tax payable by
enterpr Ises. However, leaving aside
always possible,Implementation of
administrative formalities that are often cumbenJome and costly.
Impeding cross-frontier business activity within the
community Is one of the Community
tasks. Tothat end,
Is necessary toImplement as soon
measures whose adoption should be facilitated
they do notaffect the essence of national tax
systems and their
budgetary consequences are rei at I ve
I y11m I
Measures to be Implemented as soon as possible
Directives on this
subjecttogether with a tax measure
Statute for a
shortly present two further
proposals and It Intends to
certain measures relating to the tax environment of companies"
Proposa I s a I ready
18. TheCommission has put forward a package of three proposals
enterpr I ses fromdifferent Member States:
" Direct I
19. Thisproposal provides for any
capital gainsarising from a
merger, adivision or contribution of
assets or an
shares to betaxed not at
the time ofthe operat Ion In Quest
but onlywhen capital
the conditions which Member States may Impose on the deferral of
formation of European companlee, by merger, which Is
method offormat Ion
Statute for a
European company presented by the commission In August 1989.
The "parent companies and subsidiaries" Directive
20. Thisproposal Is Intended to eliminate the double
dividends distributed by
Member State. To that end, It provides for:
abolish any withholding tax;
the Member State In which the parent company Is established to
exempt thedividends or else
tax them while at
timeImput Ing the tax charged In the Member State In wh Ich the
subsidiary Isestablished against Its own
The "arbitration procedure" Directive
procedures designed to
ensure, within specified
elimination of double
taxation that occursIn connection with the
adjustment of the profits of associated enterprises when an upward
adjustment In an enterprise
In oneMember State Is not
accompanied by a corr.espondlngadJustment In the
Member state. To
agreements and, secondly, for
theIntroduction of an
must be In.ltlated automatically
the failure of
the amicable procedure and which mustlead to the elimination of double taxation.
prOblems raised by
have been resolved,
cons I dersIt essent I a I
for theCounc II to
adopt them as
sslble, as It was urged to dO by
theEuropean Council at
meeting In Strasbourg InDecember 1989.
(2)Proposa I s to be presented
(a)Need for account to be taken of fore
I gn prof I tsor losses
In Itsproposal for a Council Regulation on the Statute for a
Europeancompany, the commission Included provisions (Article 133) stipulating that, where, during a
prof I ts
II shments wh I ch
European company has
InII Memb~.r State or third country
loss may be offset . aGainst the prof
European company In the Member State where
ItIs resident for
losses to be
taken Intoaccount at company level
engaged Intransnational activities.
will therefore shortly present a proposal for a Directive covering
allcompanies Irrespective of
Thatproposa I w I II
a I sodea I
subs Id lar les established abroad.
practicalImplementation of the solutions set out In the
Member states apply the same arrangements for the carry-
currently differ -
casesappreciably - as regards . the
possibility of carry-
losses which maycarr led forward or back.
In 1984, .
theCommission presented a
proposal for aDirective on
I zat Ion
ofsystems for the carry-
forward and carry-
oflosses for tax purposes, on wh
I chthe Counc II has not yet taken
Council to resume Its
that proposal , which has been held UP
for anumber of years, with a view to Its speedy adoption.
payments within groups of companies
Arrangements could be
gradual abolition to help those Member states which are
capital andtechnology and for
which thetaxes on
these payments represent an appreciable source of tax revenue.
(3)Other measures to be taken
(a)Rules and regulations governing transfer pricing
procedure will guarantee theabolition of
double taxat Ion occurr Ingbetween assocIated enterpr
econom I c
compared with the present situation, the best solution would be to
prevent any double taxat Ion.
ofMember states' rul.
In which are the main cause of
taxation) with a view tomaking them more uniform. It will also
administrations concerned where one of them Intends to adJust the
companies or establishments of
greatly facilitate such cooperation.
Transparency Of Incent
28.In almost all the Member States company taxation Is used as a
vehicle for Incentives through which economic or structural policy
pursued. Ofcourse, where
such measures take the
form of aid, the Treaty rules on competition apply.
from the lack of
specific taxmeasures. Most of them take the form of special tax
Increasingly making the tax base more complicated, for
me.dlum-slzed firms, this lack of transparency and complication may
prejudicial and may
Impecle the developmentof cross-
act I v I tl es .
Intention of questioning the aim
Ives, provided that the Treaty obllgatIons are observed.
However, Member States should examine their legislation to ensure
more transparent. For
Incent Ives In the form of base
reduct Ions could
be converted Into
tax credits or rate reductions.
( c) DIrect app
II cat Ion of the Treaty
part Icular, the
free movement of capItal cannot be
hindered by tax
Problems of company
taxation raised by thedevelopment of the
The need for new longer-term guidelines
taxharmonization at Community level
examined as long ago asthe first
half of the
1910s by various
particular theWerner committee,
Subsequently, In 1915, the Commission presented a proposal for a
Direct Ive on theharmonlzat Ion
sYstems and rates ofcompany
taxationIn the Member
aim was tolimit the economic
double taxation of distributed dividends.
That proposal, which has not been discussed by the Council
European Par IIament for more than ten
years now, wasbased on a
Icular since theSingle European Act
Commun I ty
drawn up InApr II 1989
EuropeanCouncil, a new approach to economic Integration has been
This approach gives priority to the
of policies rather than to systematic use of
harmonization. It .
also clearlyIn keeping with
In the tax field, priority has been given to removing tax barriers
abolishing all forms of double taxation between now and 1993.
Under the circumstances, the 1915 proposal, which, In any case, no
longer corresponds to the current situation
Instances of doubletaxation between Member States can be
resolvedIn other ways.
completion of the Internal market between now and the end of 1992
physical andtechnical barriers will
disappear and the differences
Increasingly apparent and
Investment decisionsIn this
question arises as
whether further actIon on direct company taut Ion Is
a I ready
const I tutes
gradualcomplet Ion that phenomenon.
competition between the different economies
theap-prox Imat Ion
thecompany taxation field
fur theramp II fy
For example, the tax base and
the rates ofcorporation tax have
reform which was
cuttingnominal tax rates while at
I sreform offers
theadvantages of transparency and
prove particularlybeneficial to
sma II and med I um-s I zed
question arises ,as to whether
In view of
relatively major differences between Member
states asregards the
taxburden on companles,
thisspontaneous alignment will
anIntegrated market and
whether It will lead to economically desirable taxation.
attempt byMember States to
cutt Ingcompany taut
terms of loss of
budgets or of
equity asregards Its Impact on the distribution of
the tax burden within each Member State between the various taxes
Study of new proposa
conditions and In order to be
able to e.
whether or not new measures are advisable, the commission sees a
need for afresh studY which will have to
take account, firstly,
ofthe current state of, and
prospects for, community
and, second I y ,
theresu I ts
1980s, both Inside and outside the community.
I sstudy w
III beentrusted to a comm I
ttee made up
Independent persons chosen for their expertise. This
for which the Commission will provide the secretariat, will have to submit Its report within a maximUm period of one year.
The study will have to answer the following main questions:
(a) do the disparities which exist between corporation taxes1 and the tax burdens on companies from one Member State to the next
InInvestment decisions affecting
functioning of the Internal market?
(b) If so, can those distortions be eliminated simply through the
Interplay of market forces and
competition between national
tax systems or ar.e Commun
I tymeasures requ I red?
(c) Should any action at Community level
concentrate on one or
elements ofcompany taxation,
corporat Ion tax systems, the differences in
associated with the legal status of companies , the tax base or
env I saged
toharmon I za t Ion
framework for national taxation? What would be the effect of
such measures or the absence of such measures on Co/llmun I ty
objectives such as cohesion, environmental protection and fa.
t rea tment ofsma II and med I um-s I zed
In the light of
thisstudY, the Commission will decide what proposa I s for measures It shou
I dpresent to the Council.
Stepping-up of consultations
36.In order to promote cooperat Ion wi th representatives from the
Member States, the Commission considers that consultations should
be stepped up In th
I s fie I
d between those responsI b I e for taxat Ion polley In the various Member States. Meetings Should be held at
regularIntervals, at least once or twice a year, to
viewpoints with the Commission on
Member States to take account, In pursuing their national tax
both theImpact of
Internal market and
consequences of those pol icles for the other Member States In the
context of the growing
Integration and sol idarity
Community economies. These meetings should deal not only with the problems which arise within
't-heCOmmunity. but also
encountered In relatl.ons withnon-member countries.
- 13 ~
The Commission Invites the
Council and Parliament to:
take note of the withdrawal of the 1975
proposal concerning theharmonization of systems of company taxation and of
taxes ondividends and of the guidelines
resulting from this
In thelight of
completion of the Internal market by the end of 1992 and beyond;
endorse the Commission
s decisions to:
arrange for a study to be made of thecompany problems posed by greater economic Integrat Ion;
In thecompany taxation field with
The Commission asks the Council:
to adopt without delay the following proposals which have already been transmitted to It and which are of special Importance for the
estab I I shment of the
I nterna I
the proposal for .a Directive on a common system of
taxationapplicable to mergers, divisions and contributions of assets
Involving companies from different Member States;
the proposal for a Directive on a common system of
taxationapplicable to parent companies and subsidiaries from different Member States;
proposal for a
Introducing an arbitration
procedure for eliminating double taxation in the event of the
adjustment of prof Its between assoc
enterpr I ses.
examine In the
arrangements for the taking Into account by the parent company
of foreign resul
the abolition of wltholdlng
taxes on royalties and .
(SituationaE) at 1.
nONSBETWEEN MEM9ER STATES NOT COVERED BY A BILATERAL AGREEMENT.
~ Greece - Spa.in - IrelaD:i
- Luxembourg - Nether J.anjs
ng tax rates ap
o div1dend p
Country in which the distributin
company is estahl ished
company is established ColJntr1 cs
BelgiumDenmark Ge rmany
~on-member count ri as
.- -. .- ~ ~ -
-SwitzerlandUni tcd Sti4tes
Denfilark (1 )
(?J . Ge rmi1ny
25(25)15 (10 10(SOV'
-10(10) 15 10(25) 15
5 (25)10(25) 15 10(25) 15 10(50) 15 5(25) 15 0(25) 15 10(25) 15 0(25) 15
Source. International Bureau of Fiscal Documentotion
Un it ~d
(2)(1 ) ----, It
10(25)5 (7.5) 1-5 (I) 5 (-25)
0(10) (5 (25)
0 (10) (
5 nO) (
) c,m f
0(10) ((J'. Kingdom
(7)20 (B) 15 (8)
715(8)I)) 15 (8)'
( 1 ) Rate applicable in the case of a
peroentage require1 for a
hol.d.i.ng to l::e
iIxiioa:tai in brackets.
(2) Rate applicable in the case of a
(;3) Four rates
deperrlirJg on the
bearer shares registere1 shares
shares quote1 on the
shares DOt quote1 on the
(4) Rate raiuce:l to 5% if the recipient cornp:myis DOt liable to
on the same
di vi nemB
(5) Cases whe:reSwiss companies are
oont:rolle1 by Swiss residents.
(6) Rate for a hol.d.i.ng of
at lea.st Iffi.: Iffi..
(7) No tax cre1it grante1.
crErlit grante1 =
25/75 Of the divideIrl.
crErlit grante1 =25/150 of the dividerd.
(10) Rates provided for by the bilateral agr-eement in practice the rate of 15 % i~ also applicable in the case of a substantial holding.
~SAPPLIC'.ART:R 'IO LOSSES
Summa.ry table sbDwiDg the extent to which losses nay he offset wi
e.achMember State am. in
with other countries.
reE:i(ient in the same State
losses of such e.':rt-.e1'1' ;
~hmentsare always inoludai in the
companys results, in all Member States.
consortiumJl\EX1.t)S a ho1d.i-'og company owna:l
by a. grou.p Of
Irelar.d ,a. IDaXimtun of
Member State BeLgium Denmark Ge rmany
Subsidiary in the Member State
Conso L1dati on (consoLidated profits)
(whol Ly owned
otfsett log where "Drganschaftff (subsidiary under financiaL, structuraL and economic control)
gn estab L
Offsetting with reincorporat1on in a given
order(Arti 66 !l
Where no a~reement: imputation - Deduction wi
th r(!incorporation where an
agreement provides for exemption
- Where no agreement: imputation - In accordance with agreements: exemption
in principLI? but deduction of losses
Consolidation if appLication of: (i) consoL iaated profits
tmputation under worLd profits system if opt ed fo r by
Imputation method in
the overall resuLt o'
r all permanent
establishments is negative (no deduction losses in such cases)
Consol idatipn (consol idated profi ts) (wholly owned subidiary) ConsoLidation if application of:
(1) "consolidated balance sheet
" (very limited use
An practi ce)
(ii) provisions for losses in the
5 years if
within the EEC
, with automatic
rei ncorporat ion(~rt. 39(S)(D)
1 reland Consol idation
subs i di ary,
Imputat ionmet hod
deduc t i on
Combi net ion
exerrption with progression in case of
(subs i di
OerJuc t ion
re i ncorpo rat i
un; latera l
Un it ed
Ht.lltM:.:. '" LA
5 AU t'AII:J4.NI U.
1NIH!I:.IS lN11(( lNTHlPH(~lS
Situation ou 1.
Etat de ril'
IBellli quelDonemork IAII
I du dubl teur
I Etot de reeldence
I do benuflclalre
Pay. eons convent
Be I 51 r
15( 10) I
DanlllliOrk A I I
Groce Eepagne Fronce
Portugal Royoum...un I
Source: Internat lanai
Bureou of F Ilcal Documentat
Rema r cue
(1) pas de retenue sur
- les Inter&ts sur dettes commerclales;
- les Inter&ts payes par des banques etablles en Belgique a des banques etrangeres
(2) unlquement d'appllcatlon pour une participation d'au molns 25%; pas
de retenue dans les autres cas;
(3) pour les socletes non-resldentes,Ie taux est egal au taux de
I' Imp6t des soc letes;
(4) exonerat Ion pour
lEIs Inter&ts payes a121
Deutsche Bundesbank ou .121 Kredltanstalt fur W!ederaufbau;
(5) hux du droit Interne avec un grand nombre d'
(6) a part certaJn\paJements exoner6s;
applicable dans Ie cas
de so.cletes sulsses contr61ees par
des residents sulss.es;
(8) retenue de 35% sl Ie beneflclalre est LIne socllHe qui detlent
50% des participations dans 121
(9) retenue de 10% pour res Inter&ts
re I at I fs
aux emprunts garant Is pardes banQues allemandes, a condition que
!es emprunts solent
offlclellement reconnus comme etant dans l' lnter~t economlQue ou
I (tat de resIdence
I Etat dElr..ldonce
Paye sane convention
I 33 1/3 I
I Eapogne 1
I "ronce 1
I Holle 1
1 - 1
I Sui... 1
I Etoh-tlnl. 1
I Japan 1
J I na pas Gte tenu compte de la T. A. que certains pays appllQuent sur les
(2) taux applicable pour des socletes sulsses contr~Jees par des
(3) taux appliqUe
;\ 70" du montant brut, c
dlre un taux effectlf
Situation at1 January 1990
Tab t e: Tax arrangements appliccble to the carry"over of losses
,maximum numb'er of
maxlmum ~umber Qf years authorized
Commuo;ty Se 19ium Denmark Germany
Uryi t eo Ki ngcom
no l ;mit
of. riscalDocumentation for the Member
' and Lybrand fon theother
countries-xcept,ons: .- for-compaI1:i,.e.s:e.stabLisbed a:fter 1 Jemu8ry 19.72,
no Limit on carry-forward of Losses in iir$~
5. y~ar~~~ for compulsory deprec;ai'ion: no limit on !=C!rry-fo
Amount L im;ted to DM 10 OO~
4 Five yearsfor hoteLs
... mines and
Under ~ertain ~onditions.
Under certain conditions.
As a rule
, a tax period covers two years.A loss in one ye~r '
C!lu"toma'ticesLl..y c~rried over
'to thesecond year of the same period.
;in the case ofF.ederal taxes the loss incurred in one period may' carried forward for three periods.
Revenve from corporati on t~x, 1987
Revenue from corporation tax
"As. a per..ceo:!age
As- B. percent-age. .
tota L t~x-~~ven~e
De:)nia r j(
On ft e.d Kingdom
SOlJrce ' OE~J)
Imp8t des soclet.s
Toux de "lmpBt sur
Taux dO credit d'
IToUX de lu retenue a 10
Ie beneHclolre resident
18ource pout Ie beneflclolre
lottenuot Ion ou avec euppr...lon I
Ide 10 double hillposltlon
I benefice non
I en ~ de PlmpSt
I en ~ du dividend. I
I dill eoclete.
5....t- .on. attenuation
SuJue12. S...steme ottenuot Ion Japan
43(2) 34(3) 38,
toux progresslfs 35(13)
368(9) 34( 11) ( 12)
18. 69, 189(7) 189(18)
4 a 12
25(4) 15(5) 38(8)
From 1 January 1989 Belgi1.Ul1 a'bo' i ~::"h~ its relief system for natural
persons who do DOt appropriatetheir investment :incOme to
Sta;r:x1ard. rate for profits in
excessof BFR 16 000
wiD. bereduca:l to
41% from 1J8lIUB.I'Y 1991 ,
1 Ja.nu.a.ry 1992.
Stamard rate forprofits in excess of LFR 1 312 001; an addi
tionaJ.cba.rge of 2%
is due .
for the employment f'urrl
, l:e.sai on theamount of
:f'u11 discha.rgeof tax , i flhi .
apply to di
compani as .
With coupon sta. tement.
1~of the tax on
FOI.1r rates are applied:
Shares quotei on the Athens stock exc'ha.DQ'
Shares DOt quotedon the Athens
:bearer sha.res 46% 8m:.
registere:i sha.res 42% 47%
National rate of tax
plus 1000.1 tax, or ILOR, at 16.
'!be tax c:rati.t re1a.tes on1 Y to the national tax of
Stan:la.rdrate at Federal level for profits not
IDUnicipa.l taxes must
bea.ddOO. to Faie.ral tax. In the
oase of New York, for iDst.cmoe, the overall rate is 45. 25%
At Fe:1eral level, the tax is
caJ.cula;tej. on the1:as1s of the
ratio(%) of taJrable profits to e;ru.1 ty . Ra. tes are progressi vean:l rapg
6.$ to 9.8%. To this abarge must .be a.ddOO.
which range from 7. 8% to 22
. 6%ani are
de1uct1b1e from the base for Fe:1eral tax pu.rposes.
In the case of ZUrich, for 1Dsta;ooe, the cambina.tion Of the
overallt.aJt. rate of between 11.
1% am30. 2% .
National tax rate.
I FI CHE
Commission auConge! I
Parlement europ6en et au Comlt6 Economlque et Social sur
orlehtatlons en mat
litre de flscallt6des entreprlses
fiche f Inanc I ere
La fiche flnanclere est necessalre comme complement a I'
annonce dans Ieprojet de communication des imp
I I cat Ionsbudg6tal res de
flscale estreconnue et qUi sera amene a remettre une etude
dans un delal d'
un an enrepondant aux pr inclpales quest Ions cltees au paragraphe 34 de la COmmunication
II est envisage de conclure avec ces personnalltes des contrats
services,eventuellement Indivlduels, de
manlerea remunerer sur base des contrats-types ex Istants les travaux des membres de ce " Comlte" ; leg credits operatlonnels de la DG XV (87752) et/ou la dotatlon de la DG XV sur Ie posta A2600 devront etre ut Illses a cette fin
Comite", en reallte un "
experts" de la Commission, sera appele a se reunlr a plusieurs reprises tout au long de
ses travaux ; leg credits disponlbles sur Ie poste A2500 en
dotation de la DG XV devront etre utilises pour
frats de voyage, d'approche et de sejour de ces experts prlves.
(a) credits d'
prestat ion de service pour la
remise d'une etude
I I estpravu de conclure 5 contrats d'une duree de douze morsel raison de 20. 000 ECU par contrat
total: 100.000 ECU a Imputer sur leg cr6dlts d'engagement pour
I 'annee 1990 du posta
87752; sI necessa
I re unrenforcement de ces postes sera deman6d en temps utile.
(b) frals de convocation pour
la reunion de ce "
prevu deconvoquer ce
experts prIves a 6
la duree de
castravaux dont 4
convocations durant "annee 1990
total: 12.000 ECU a lmputer sur leg credits du poste A2500
fra I s
approche et de sejour de ces experts